Lord Jones of Birmingham: The OFT can offer general guidance on consumer credit licensing, but its advice cannot be taken as an authoritative view of the law. What is or is not regulated consumer credit business, within the meaning of the Consumer Credit Act 1974, is ultimately a matter for the courts. Whether or not a licence is required will be dependent on the individual circumstances applicable to the operation of each individual club. It is not possible to list all the specific circumstances that would require clubs to be licensed, since OFT cannot be aware of all the facts. Consequently, OFT would advise individual clubs to seek independent legal advice if they are in any doubt.
	However, if a club is carrying on business, allows payment of membership fees in more than four instalments and its agreements are not subject to any exemptions, it may need a consumer credit licence. Guidance on exemptions is available in the OFT publication Regulated and Exempt Agreements (OFT140), which is available on the OFT website at www.oft.gov.uk/advice_and_ resources/publications/consumer_advice/money_credit_debt/oftl40.